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Business Blog

Order compliance: A behind-the-scenes look

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If the Commission is to attain the objectives Congress envisioned, it cannot be required to confine its road block to the narrow lane the transgressor has traveled; it must be allowed effectively to...
Business Blog

FTC calls Sprint on $2.9 million risk-based pricing violation

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Two people walk into a deli and both order a pastrami on rye. When the check arrives, one is charged $8. The other is surprised to get a bill for $15.99. That’s not the start of an old Henny Youngman...
Business Blog

Are you OK with the F-C-R-A?

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The Fair Credit Reporting Act isn’t just about credit. If your company uses background checks in making personnel decisions, the FTC reminds you of your obligations under the FCRA. In honor of...
Business Blog

Why 603(y) doesn’t apply

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Does your company use background checks in evaluating job applicants? If so, are you complying with the Fair Credit Reporting Act’s notice, consent, and disclosure requirements? A closing letter the...
Business Blog

Third Circuit rules in FTC v. Wyndham case

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FTC watchers and data security mavens, it’s the decision you’ve been waiting for. The United States Court of Appeals for the Third Circuit has issued a ruling in the Commission’s favor in FTC v...
Business Blog

Mess ipsa loquitor? Letting the facts speak for themselves

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This post about the FTC’s law enforcement action against Craig Brittain will be a little different. No bullet points parsing the nuances of complaint allegations. No tips and takeaways for savvy...
Business Blog

Testing, testing: A review session on COPPA and schools

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We often get questions about how the Children’s Online Privacy Protection Act applies in the school setting. The COPPA Rule gives parents control over what information “an operator of a Web site or...
Business Blog

The FTC's TRUSTe case: When seals help seal the deal

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People who aren’t into marketing jargon might not know a “credence claim†from a Creedence Clearwater Revival, but experts tell us it’s a representation about a product that consumers aren’t in a...
Business Blog

Big COPPA problems for TinyCo

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Fans of Tiny Pets, Tiny Zoo, Tiny Village, Tiny Monsters, and Mermaid Resort will be relieved to know that adorable Sully the Dog and arch-nemesis Duke Spendington haven’t been named in their...
Business Blog

Gone with the wind?

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A mobile app that lets users send photo and video messages that recipients can look at for a moment before the content is, in effect, gone with the wind? Scarlett O’Hara could have declared her love...
Business Blog

Checking up on consumer generated health information

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Whether it’s a website where people diagnosed with the same medical condition can share their stories or an app to find out how long it will take in the gym to burn off a Macadamia Mania Ripple sundae...
Business Blog

FTC staff to Facebook and WhatsApp: Privacy promises prevail

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When one company acquires another, there’s usually a lot of discussion about how to harmonize divergent procedures – everything from personnel policies to buying paper clips. But a letter to...
Business Blog

When a data oops becomes an uh-oh

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We’ve said it before, but it bears repeating: Glitch Happens. In the case of Accretive Health, Inc., it was a laptop taken from the passenger compartment of an employee’s car. What transformed this...